Inherited IRA Advisor Match

Inherited TSP Rules: 10-Year Rule, Rollover to Inherited IRA, and the 90-Day Deadline

The federal government's Thrift Savings Plan covers roughly 6 million current and former federal employees and military members — making inherited TSP accounts one of the most common large inherited retirement accounts families encounter. If you've inherited a TSP, you're working with rules that are mostly parallel to inherited 401(k)s and IRAs, but with several TSP-specific mechanics that can cause serious, irreversible mistakes if you don't act in time.

The most critical difference from inherited IRAs: Non-spouse beneficiaries of a TSP account do not have open-ended time to decide. TSP creates a temporary account in your name, but if you take no action within 90 days, TSP will automatically distribute the entire balance to you as a taxable lump sum. There is no do-over and no redeposit. If you want to roll to an inherited IRA and preserve the 10-year deferral window, you must request the direct transfer before day 90.

What is the Thrift Savings Plan?

The TSP is a defined-contribution retirement plan administered by the Federal Retirement Thrift Investment Board (FRTIB) under 5 U.S.C. §§ 8431–8440. It covers:

The TSP offers five core funds (G, F, C, S, I) plus Lifecycle (L) funds that blend them by target retirement date. The plan's administrative expense ratios are among the lowest available for retirement accounts — roughly 0.05% per year — which is a material advantage worth considering when deciding whether to roll an inherited TSP balance to an inherited IRA.

Participants can hold both traditional (pre-tax) and Roth TSP contributions within the same TSP account. The 2026 elective deferral limit for TSP participants is $24,500 ($32,500 with the age-50 catch-up; $35,750 for those ages 60–63 under the SECURE 2.0 super-catch-up provision).1

Does the SECURE Act 10-year rule apply to inherited TSP accounts?

Yes. The TSP is a qualified retirement plan under IRC § 401(a), and the SECURE Act's 10-year depletion rule under § 401(a)(9)(H) applies to it. If you inherited a TSP from a decedent who died on or after January 1, 2020, and you are a non-EDB beneficiary, you must deplete the account by December 31 of the 10th calendar year following the year of death.2

In practice, non-spouse beneficiaries must first roll the inherited TSP balance into an inherited IRA at a private custodian — because the TSP's temporary account structure does not allow long-term deferral. The 10-year rule then applies to the inherited IRA.

Year of death10-year depletion deadline
2020December 31, 2030
2021December 31, 2031
2022December 31, 2032
2023December 31, 2033
2024December 31, 2034
2025December 31, 2035
2026December 31, 2036

Non-spouse beneficiary rules: the 90-day window

When a TSP participant dies, the TSP locates and notifies beneficiaries based on the participant's TSP-3 Designation of Beneficiary form (or, if none is on file, the statutory order of precedence: spouse → children equally → parents → estate). Once the TSP has processed the death claim and established a temporary account in the beneficiary's name, the clock starts.

What the temporary account is — and isn't

The temporary TSP account holds the inherited balance while you decide what to do with it. It is not a long-term holding account. You cannot make contributions to it, designate new beneficiaries on it, or let the balance sit indefinitely. The only decisions are:

  1. Request a direct rollover to an inherited IRA — the most tax-efficient choice for most non-spouse beneficiaries who want to stretch distributions over the 10-year window
  2. Request a partial or full lump-sum distribution — fully taxable as ordinary income in the year received

If you do not make a request within 90 days, the TSP will automatically process a full lump-sum payment and mail you a check or wire. That distribution is taxable in full and cannot be returned or redeposited. The 90-day deadline is not a suggestion — it is automatic.3

The direct rollover requirement

A non-spouse beneficiary cannot receive the TSP distribution personally and then redeposit it into an inherited IRA. Unlike a 60-day rollover that a participant could do with their own account, the non-spouse beneficiary option is direct rollover only:

Traditional TSP funds roll to a traditional inherited IRA. Roth TSP funds roll to an inherited Roth IRA. If the TSP account holds both, the rollover must be bifurcated accordingly.

Annual RMDs during the 10-year window: T.D. 10001 applies

Once the inherited TSP balance is in an inherited IRA, the same pre-RBD vs. post-RBD split that governs inherited IRAs and inherited 401(k)s governs the 10-year window. IRS final regulations T.D. 10001 (July 2024) apply through § 401(a)(9), which covers all qualified plans including the TSP.4

Decedent died before their Required Beginning Date (pre-RBD)

No annual RMDs are required in years 1–9. You may take distributions in any amount and at any time during the 10-year window, as long as the account is fully depleted by the year-10 deadline. You can take nothing for nine years and distribute everything in year 10 if that works for your tax situation.

The Required Beginning Date (RBD) for a TSP participant is April 1 following the year they turn 73 (for those born 1951–1959) or April 1 following the year they turn 75 (for those born 1960 or later), per SECURE 2.0.5 The "still working" exception that applies to some 401(k) plan participants does not apply to TSP accounts — TSP participants must begin RMDs by their applicable age regardless of employment status.

Decedent died on or after their Required Beginning Date (post-RBD)

Annual RMDs are required in years 1–9 of the 10-year window. Each annual RMD is calculated using the Single Life Expectancy Table (IRS Publication 590-B, Table I, updated per T.D. 9930 effective 2022) based on the beneficiary's age in the calendar year after the year of death. The divisor is then reduced by one each subsequent year.

The 2021–2024 IRS waiver notices (Notices 2022-53, 2023-54, 2024-35) excused missed annual RMDs from inherited accounts during that period. Those waivers have expired. Annual RMDs for 2025 and later are required. Missed distributions are subject to a 25% excise tax under IRC § 4974, reducible to 10% if corrected within the correction window. See our missed inherited IRA RMD guide for the Form 5329 correction process.

Year-of-death RMD

If the TSP participant died after their RBD but had not yet taken their full RMD for the calendar year of death, that shortfall is the beneficiary's obligation — due by December 31 of the year of death. This applies to inherited TSP accounts exactly as it applies to inherited IRAs. If you're rolling the TSP to an inherited IRA before year-end, confirm whether a year-of-death RMD is outstanding and take that distribution before completing the rollover (or have the plan compute and pay it out directly before transferring the remainder).

Surviving spouse: the Beneficiary Participant Account

A surviving spouse who inherits TSP funds has more options than any other beneficiary. The most significant: a surviving spouse can transfer the inherited TSP balance into a Beneficiary Participant Account (BPA) — a special TSP account held in the surviving spouse's own name that operates differently from either the decedent's original TSP or a standard inherited IRA.6

What the BPA allows

Alternatively: roll to own IRA

A surviving spouse can instead roll the inherited TSP to their own IRA (not an inherited IRA — their own traditional IRA). This resets the clock entirely: RMDs don't begin until the spouse's own RBD age, and the Roth TSP can be rolled to the spouse's own Roth IRA with no RMD requirement ever. See our surviving spouse inherited IRA guide for the full four-option comparison, including the critical under-59½ penalty consideration.

The Roth TSP exception in the BPA

Starting in 2024 under SECURE 2.0, Roth TSP accounts in a BPA are exempt from RMD requirements — parallel to the Roth IRA exemption. A surviving spouse holding Roth TSP funds in a BPA owes no annual RMDs on those funds during their lifetime.

The successor beneficiary trap: unique to the TSP

This is the most consequential TSP-specific rule that does not have a parallel in inherited IRAs, and it affects estate planning significantly.

When a surviving spouse holding a BPA dies, the successor beneficiaries — the people the surviving spouse named on the BPA — cannot maintain funds in the TSP and cannot roll the funds to an inherited IRA. The TSP must distribute the remaining BPA balance to the successor beneficiaries as a taxable lump sum. There is no rollover option, no 60-day window, and no inherited-IRA alternative.7

Contrast this with an inherited IRA: when a surviving spouse inherits an IRA and rolls it to their own IRA, their successor beneficiaries (the new beneficiaries they name) inherit the account as a normal inherited IRA and have the full 10-year window available to them.

Planning implication: A surviving spouse who rolls an inherited TSP balance into their own IRA (rather than maintaining a BPA) protects successor beneficiaries from the lump-sum-only outcome. The tradeoff is losing TSP's low expense ratios and the ability to defer RMDs using the decedent's RBD age. For large TSP balances where the successor beneficiary planning matters, the rollover-to-own-IRA route is often the better long-term choice.

Eligible Designated Beneficiary exceptions

The same EDB categories that provide a stretch-IRA option for inherited IRAs provide a stretch exception for inherited TSP accounts. If you are an Eligible Designated Beneficiary, you are not subject to the 10-year rule and may use the Single Life Expectancy Table to calculate annual RMDs over your own lifetime:

Most adult children who inherit a parent's TSP are non-EDB beneficiaries subject to the 10-year rule.

Inherited Roth TSP: how it works

Roth TSP funds can be rolled to an inherited Roth IRA via direct rollover. Once in the inherited Roth IRA:

TSP vs. inherited IRA: should you roll over?

For non-spouse beneficiaries, rolling the inherited TSP to an inherited IRA is the only way to maintain the 10-year deferral window — the TSP's temporary account doesn't support long-term holding. But there are a few factors worth understanding before you transfer:

FactorInherited TSP (temporary account)Inherited IRA
10-year window flexibilityNo — must request rollover within 90 daysYes — full 10-year window
Investment optionsLimited to G, F, C, S, I, L fundsAny publicly traded security
Expense ratios~0.05% — among lowest availableVaries by custodian and fund choices
Creditor protection (federal bankruptcy)Strong federal protectionNo protection per Clark v. Rameker (2014) — see creditor guide
Loan optionNot available to beneficiariesN/A
Successor beneficiary rolloverLump sum only (for BPA survivors)Standard inherited IRA rules apply

In practice, most non-spouse beneficiaries benefit from rolling to an inherited IRA at a major custodian (Fidelity, Vanguard, Schwab) because the investment flexibility, distribution control, and 10-year window access outweigh the marginal cost advantage of TSP's low expense ratios. If the TSP balance is very large and the beneficiary has creditor exposure concerns, the analysis is more nuanced — that's a case where a fee-only advisor familiar with both TSP rules and inherited IRA planning adds material value.

TSP beneficiary designation: critical estate planning gotchas

Form TSP-3 controls — not your will

TSP assets pass by beneficiary designation, not through probate. If the deceased participant had a TSP-3 form on file, those designations control absolutely — they override the participant's will, trust documents, and any verbal instructions. If the participant died without a TSP-3 on file, TSP uses the statutory order of precedence: surviving spouse → children equally → parents → estate.

Federal law governs — state revocation laws do not apply

Some states have laws that automatically revoke an ex-spouse's beneficiary designation after a divorce. These state laws do not apply to TSP accounts — the TSP is governed by federal law (5 U.S.C. § 8424), and federal law does not include an automatic post-divorce revocation rule. An ex-spouse named on an old TSP-3 form receives the funds regardless of a subsequent divorce. Federal employees should review and update their TSP-3 after any major life event.

TSP beneficiary designation is separate from all other accounts

Naming a beneficiary on an IRA, a 401(k), or a life insurance policy has no effect on the TSP. Each account requires its own separate designation. Many federal employees manage FEGLI life insurance designations and IRA beneficiary forms but neglect the TSP-3 — a mistake with significant consequences.

Step-by-step action guide for non-spouse beneficiaries

  1. Contact the TSP immediately. File a death notification at tsp.gov or call 1-877-968-3778. The TSP will establish a temporary beneficiary account and send instructions. Do not wait.
  2. Open an inherited IRA at your chosen custodian. Contact Fidelity, Vanguard, Schwab, or another major custodian and open an inherited (or "death") IRA specifically titled for the inherited funds. Do this before the 90-day window closes.
  3. Request a direct rollover — not a distribution. Specify the receiving custodian's account and routing information. The TSP must transfer directly; you should not receive a check.
  4. Determine the year-of-death RMD obligation. If the decedent died after their RBD and had not taken their full annual RMD for the year of death, that amount is due by December 31. Coordinate with the TSP or your inherited IRA custodian to complete this distribution before year-end.
  5. Determine whether you're a pre-RBD or post-RBD beneficiary. This dictates whether you owe annual RMDs in years 1–9. Check the decedent's birth year against the RBD age table above.
  6. Model your 10-year distribution strategy. If post-RBD: calculate your year-1 annual RMD and decide how to pace distributions to minimize bracket impact. Use our inherited IRA RMD calculator to see the full year-by-year schedule. If pre-RBD: model equal vs. front-loaded vs. back-loaded strategies using our 10-year distribution strategy guide.
  7. Consider professional help. TSP-inherited-IRA rollovers combined with FERS pension income, Social Security timing, and IRMAA exposure create genuine planning complexity. A fee-only advisor who understands both federal employee benefits and inherited IRA rules can quantify the tax savings from a structured withdrawal plan.

Inherited a TSP from a federal employee or military member?

TSP-inherited-IRA rollovers combined with FERS pension income, Social Security timing, and IRMAA exposure create genuine planning complexity that most generalist advisors never fully model. We match inheritors with fee-only advisors who specialize in federal employee estates and inherited retirement account planning. Free match, no commissions.

Related guides

  1. IRS Rev. Proc. 2025-32 — 2026 TSP/401(k) elective deferral limit $24,500; catch-up $8,000 (age 50+); super-catch-up $11,250 additional (ages 60–63) per SECURE 2.0 § 109. IRS Rev. Proc. 2025-32.
  2. IRC § 401(a)(9)(H) (SECURE Act 10-year rule); 5 U.S.C. § 8440 (TSP incorporation of § 401(a)(9) requirements). TSP Beneficiary Distributions.
  3. TSP temporary account and 90-day automatic distribution rule. TSP.gov — Beneficiary Distributions.
  4. T.D. 10001 (July 2024) — finalized inherited account annual RMD rules, including the pre-RBD vs. post-RBD split for plans subject to IRC § 401(a)(9). T.D. 10001.
  5. SECURE 2.0 § 107 — RBD age 73 for those born 1951–1959; age 75 for those born 1960 or later. IRS RMD FAQs.
  6. TSP Beneficiary Participant Account rules. TSP Publication: Your TSP Account — A Guide for Beneficiary Participants (TSPBK33).
  7. Successor beneficiary lump-sum-only rule: when a BPA holder dies, successor beneficiaries cannot maintain funds in TSP and cannot roll the balance to an inherited IRA. TSP.gov — Beneficiary Distributions; FedSmith: TSP Inheritance vs. Inherited IRA Rules.

Tax values and TSP rules verified against 2026 sources: IRS Rev. Proc. 2025-32, T.D. 10001 (July 2024), SECURE 2.0 (Pub. L. 117-328), TSP.gov beneficiary publications.